Like it or not, our country’s membership of the European Union (EU) has a way of influencing almost everything we do. A couple of new EU regulations collectively know as the EU Timber Regulations (EUTR), have started to send ripples of concern through UK companies who trade in or use materials which have their origins in forests. Paper and board can be traced back through pulp to the forests which grew the trees, so this affects you. The UK Government has added EUTR requirements to our burden of red tape through a new statutory instrument (2013 No. 233) entitled “The Timber and Timber Products (Placing on the Market) Regulations 2013.
This contains a number of new offences for failing to comply with the following: a) Article 4 (1) of the Timber Regulation (prohibition on placing illegally harvested timber on the market); (b) Article 4 (2) of the Timber Regulation (obligation to exercise due diligence); (c) Article 4 (3) of the Timber Regulation (obligation to maintain and evaluate due diligence system); (d) Article 5 of the Timber Regulation (traceability obligation); (e) Article 5 (1) of the Implementing Regulation (record-keeping obligation); (f) Regulation 10 (obstruction of an inspector); or (g) A notice of remedial actions. These regulations place particular pressure on companies bringing timber or materials containing forest products into our country from outside the EU, paper companies and merchants for example. The regulations also have implications for companies using these materials. Government powers available to deal with failure to comply with these requirements include: remedial action, seizure of material, fines and imprisonment. In order to protect your company from prosecution, you must be able to demonstrate that you have assessed the risks associated with your supply chain, have exercised due diligence in the procurement of materials and have records to support these actions. Those members of the forum who are also members of The Group Scheme will have a Chain of Custody manual, policy, procedures and records already go a long way towards demonstrating compliance. Our documentation is being updated to provide better protection. Updates will be rolled out in the New Year.
If you are not a member of our FSC Group Scheme and would like to know more, please contact me for more information.
There was an interesting article about this in Printweek, Which can be read at this link(you may need to register).